Compliance and anti-bribery

As an investment manager and adviser, a number of 3i’s activities require regulatory authorisation, licensing and/or registration. Several of 3i’s subsidiaries are therefore regulated by the Financial Conduct Authority and, where applicable, by relevant local non UK authorities, including the US Securities and Exchange Commission. For more information, please refer to the “Statutory and corporate governance section” of the Annual report.

The required standards of conduct and behaviour are promoted and enforced through a comprehensive suite of policies and procedures. Employees must be familiar with and understand the obligations and restrictions that apply to them in their 3i role, as well as personally. Employees are expected to comply with the spirit, not just the letter, of our policies and must confirm in writing, on an annual basis, that they are in compliance. We also have an internal whistle blowing arrangement which allows employees confidentially to raise concerns about behaviour or decisions that could indicate potential wrongdoings.

Our compliance team devises periodic e-learning modules, frequently followed by an assessment, which must be completed by staff.

Our compliance manual is available to all employees and covers a number of areas, the principles of which are covered in our Corporate responsibility report.

Anti-bribery policy

3i has an anti bribery policy, which applies to all those who work for, act on behalf of or represent 3i. 3i’s anti bribery policy requires high standards of ethical behaviour in all our business interactions. Accordingly, we will not offer, pay or accept bribes. In addition to detailed provisions, the policy also requires the exercise of good judgment and common sense.

3i is not aware of any breaches of its anti-bribery policy by its employees.

3i is also committed to working only with third parties whose standards are substantively consistent with its own. This includes our intermediaries and advisers.

As part of our approach to responsible investment, we expect businesses in which we invest to operate in compliance with all applicable laws and regulations including, in particular, applicable anti-bribery, anti-fraud and anti-money laundering laws and regulations.

Compliance and anti-bribery

FOR MORE INFORMATION

Corporate responsibility policies